State v. John Mann

by Martin H. Brinkley, 2006

State v. John Mann, an 1829 North Carolina Supreme Court decision, is probably the most notorious judicial opinion on the relationship between master and slave ever rendered by a state court. Written by Justice Thomas Ruffin, Mann stands for the proposition that masters were not subject to criminal indictment for a battery committed on their slaves.

John Mann, the defendant, had hired a slave woman, Lydia, from her owner. When Lydia fled minor punishment, Mann shot and wounded her. The grand jury of Chowan County indicted Mann for battery; superior court judge Joseph J. Daniel (later Ruffin's colleague on the North Carolina Supreme Court) charged the petit jurors assembled to hear the evidence that if they believed the punishment inflicted by the defendant was cruel, unwarranted by, and disproportional to Lydia's offense, the defendant was guilty under law because he was not Lydia's true master. The jury returned a verdict of guilty, and Mann appealed to the state supreme court.

That Ruffin took considerable pains over Mann is evidenced by the three drafts of the opinion that survive among his personal papers. Reversing Mann's conviction, Ruffin reasoned that a slave is "one doomed in his own person, and his posterity, to live without knowledge, and without the capacity to make anything his own, and to toil that another may reap the fruits." A slave would accept such a fate only if his master wielded "uncontrolled authority over [the slave's] body." If this authority were subjected to judicial scrutiny, it would naturally be diminished and the relationship between master and slave destroyed.

Passages from Ruffin's opinion were used by northern abolitionists as evidence of a slaveholder's admission of the moral perversity of slavery. Indeed, Ruffin, one of the largest planters in Alamance and Orange Counties and the owner of many slaves, began his Mann opinion with the observation that "the struggle . . . in the judge's own breast between the feelings of the man and the duties of the magistrate is a severe one, presenting a strong temptation to put aside such questions, if it be possible." One commentator gloated over Ruffin's discomfort: "The moral wrong of slavery is . . . admitted, along with the most resolute determination to support it, by not allowing the rights of the master to come under judicial investigation."

By contrast, Harriet Beecher Stowe, who later wrote the celebrated antislavery novel Uncle Tom's Cabin (1852), sounded a note of respect for Ruffin's candor, reporting that Mann had excited "strong interest" among English judges because of its "scorn of dissimulation" and "severe strength and grandeur . . . which approached to the heroic." To later historians Mann, with its clearly unsettling implications, expounded a doctrine of absolute dominion of master over slave that served as a reference point for southern appellate judges throughout the antebellum period.

Although some of Ruffin's language in Mann may have been excessive, the holding of the case was in fact limited; technically, the decision merely settled the legal consequences of a nonfatal battery of a slave by a master or hirer. After Mann, a master could still be indicted for killing a slave; ten years later this possibility was chiseled directly into North Carolina law by Ruffin, who had by then become chief justice of the state supreme court.

A further restraint on a hirer's or overseer's authority left intact by Mann was the threat of civil suit for damages. The master as plaintiff could seek to have civil liability imposed on a hirer or overseer for conduct similar to that of John Mann toward Lydia. Civil liability could have been only a marginal deterrent to such behavior, however, because Mann left masters-the primary employers of slaves-considerable discretion to punish slaves as their own sense of humanity dictated. By removing nonfatal batteries on slaves from the scrutiny of judicial eyes, Mann, with its notable blend of squeamishness and severity, cast a ghastly light over North Carolina slave law and the reputation of its author that has endured for more than a century and a half.

References:

Patrick S. Brady, "Slavery, Race, and the Criminal Law in Antebellum North Carolina: A Reconsideration of the Thomas Ruffin Court," North Carolina Central Law Journal 10 (1978-79).

Eugene D. Genovese, Roll, Jordan, Roll: The World the Slaves Made (1974).

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